PRIVACY (& CONSENT) NOTICE
YOUR PERSONAL INFORMATION - GENERAL DATA PROTECTION REGULATION (GDPR)
GDPR is bringing in new legal protection for personal information from May 2018. This tells you what personal information I hold and why, and what your rights are.
You will be asked to complete a signed declaration of agreement at our first face to face contact.
Therapist’s Name/Identity: Claire Mulholland MAR IIR
Therapist’s Contact Details:
Telephone No: 07801 949053
Email address: info@reflexologyderby.co.uk or claire_mulholland@msn.com
Postal Address: 7 Willington Road, Findern, Derby, DE65 6AS
Data Controller Contact Details: Claire Mulholland Mob: 07801 949053
Data Protection Officer N/A
The Purpose of processing Client Data
In order to give professional reflexology treatments, I will need to gather and retain potentially sensitive information about your health. I will only use this information for informing reflexology treatments and associated recommendations concerning aspects of health and wellbeing which I will offer to you.
Lawful Basis for holding and using Client Information
As a full member of the Association of Reflexologists, I abide by the AoR Code of Practice and Ethics.
The lawful basis under which I hold and use your information is:
- my legitimate interests i.e.my requirement to retain the information in order to provide you with the best possible treatment options and advice.
As I hold special category data (i.e. health related information), the Additional Condition under which I hold and use this information is: for me to fulfil my role as a health care practitioner bound under the AoR Confidentiality as defined in the AoR Code of Practice and Ethics.
What information I hold and what I do with it
In order to give professional reflexology treatments, I will need to ask for and keep information about your health. I will only use this for informing reflexology treatments and any advice I give as a result of your treatment. The information to be held is:
- Your contact details
- Medical history and other health-related information (which I will take from you at first consultation)
- Treatment details and related notes (which I will take after each consultation)
I will NOT share your information with anyone else (other than as required for legal process) without explaining why it is necessary, and getting your explicit consent.
How Long I Retain Your Information for:
I will keep your information for the following periods;
- ‘Claims occuring’ insurance: (records shall be kept for at least 7 years after last treatment)
- Law regarding children’s records (records shall be kept for at least until the child is 25 or if 17 when treated, then 26)
Your data will not be transferred outside the EU without your consent.
Protecting Your Personal Data
I am committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, I have put in place appropriate technical, physical and managerial procedures to safeguard and secure the information I collect from you.
I will contact you using the contact preferences you have given me in relation to:
- Appointment times
- Reflexology information or information related to your health
- Special offers and promotions (you may unsubscribe from this at any time)
Your Rights
GDPR gives you the following rights:
- The right to be informed:
To know how your information will be held and used (this notice). - The right of access:
To see your therapist’s records of your personal information, so you know what is held about you and can verify it. - The right to rectification:
To tell your therapist to make changes to your personal information if it is incorrect or incomplete. - The right to erasure (also called “the right to be forgotten”):
For you to request your therapist to erase any information they hold about you - The right to restrict processing of personal data:.
You have the right to request limits on how your therapist uses your personal information - The right to data portability: under certain circumstances you can request a copy of personal information held electronically so you can reuse it in other systems.
- The right to object:.
To be able to tell your therapist you don’t want them to use certain parts of your information, or only to use it for certain purposes. - Rights in relation to automated decision-making and profiling.
Full details of your rights can be found at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you wish to exercise any of these rights, please email : info@reflexologyderby.co.uk or claire_mulholland@msn.com
COMPLAINTS PROCEDURE
Your Rights Under UK GDPR
You have the following rights in relation to the personal data we hold about you:
- The right to access the personal data we hold about you (a Subject Access Request)
- The right to rectification — to have inaccurate or incomplete data corrected
- The right to erasure (‘the right to be forgotten’) in certain circumstances
- The right to restrict processing of your personal data
- The right to data portability — to receive your data in a structured, machine-readable format
- The right to object to processing, including for direct marketing purposes
- The right to withdraw consent at any time where processing is based on your consent
If you believe we have not respected one or more of these rights, you are entitled to raise a formal complaint using the procedure set out in this document.
How to Make a Complaint
Please submit your complaint in writing — [either by post or by email] — using the contact details above. To help us investigate your concern as efficiently as possible, please include:
- Your full name and preferred contact details
- A clear description of your concern and which data protection right(s) you believe have been affected
- The approximate date(s) when the issue occurred
- Any relevant reference numbers, correspondence or documents
Our Complaints Process
Once we receive your complaint, we will follow the five steps below. We are committed to handling all complaints promptly, fairly and confidentially.
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1 |
Acknowledgement — within 30 days: We will acknowledge your complaint in writing within 30 days of receiving it, confirming that we have recorded it and will be investigating. |
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2 |
Requesting Further Information: If we need any additional details to fully investigate your complaint, we will contact you as soon as possible and explain what we need and why. |
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3 |
Investigation & Review: We will carry out a thorough and impartial review of your complaint. We will agree a realistic timescale with you once we have all necessary information, and we will keep you updated if there are any delays. |
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4 |
Decision & Outcome: We will communicate the outcome of our investigation to you clearly and in writing within one calendar month of receiving all the information needed (this may be extended by up to two further months for complex complaints — we will notify you if this is the case). |
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5 |
Closure or Escalation: If you are satisfied with the outcome, we will close your complaint. If you remain dissatisfied, you have the right to refer your complaint to the ICO free of charge (see Section 6 below). |
Escalating Your Complaint to the ICO
If you remain dissatisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) — the UK’s independent supervisory authority for data protection. This service is free of charge.
ICO website: https://ico.org.uk/make-a-complaint/
ICO helpline: 0303 123 1113 (Monday–Friday, 9am–5pm)
ICO postal address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
THERAPIST’S RIGHTS
Please note:
- if you don’t agree to your therapist keeping records of information about you and your treatments, or if you don’t allow them to use the information in the way they need to for treatments, the therapist may not be able to treat you
- Your therapist has to keep your records of treatment for a certain period as described above, which may mean that even if you ask them to erase any details about you, they might have to keep these details until after that period has passed
- Your therapist can move their records between their computers and IT systems, as long as your details are protected from being seen by others without your permission.
June 2026

